More than 40,000 Americans die in highway accidents across the country each year. Often grieving relatives and friends feel a deep emotional need to leave a tribute to their lost loved ones by erecting modest roadside memorials near accident scenes. These wayside markers include Christian crosses, real or artificial flowers, a photograph or favorite keepsake of the victims, and a few words of remembrance.

Sometimes they stand for years, kept fresh and clean and repaired by those for whom the sadness never dims.

Though motorists whizzing by catch only a glimpse of them, the humble memorials can convey a sobering reminder to take care: death on the road stalks the careless and unaware.

But so many homemade markers are popping up that many jurisdictions now forbid them and tear them down if they appear. Some states outlaw them on the theory that the markers themselves are a traffic hazard, though troopers and maintenance crews have been known to ignore the rules and leave them up out of sympathy. Over time, neglected markers turn shabby. Or just the opposite happens: people add so many elements that they begin to look like elaborate monuments.

Recently The Washington Post wrote about a woman in Maryland who lost her husband in a 2003 motorcycle crash. His last spot as a living person on earth is a sacred place, she said, so she built a small tribute nearby. But this year, after five years, the state said the memorial had to go. It was a fairness issue, authorities said, since other private groups and individuals are not allowed to put up signs.

The woman was crushed. "I think anyone who touches the life of someone else . . . shouldn't be forgotten," she told the newspaper.

The memorial was allowed to stand through the anniversary of her husband's crash. Then she took it down and carried the pieces home.